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Interpretation Response #07-0225 ([Packaging Applications for Dangerous Goods, LLC] [Mr. David Gluntz])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Packaging Applications for Dangerous Goods, LLC

Individual Name: Mr. David Gluntz

Location State: OH Country: US

View the Interpretation Document

Response text:

February 25, 2008

 

 

Mr. David Gluntz                                                                                 

Packaging Applications for Dangerous Goods, LLC

3583 Blackbottom Court,

Columbus, OH 43221-4501

 

Ref. No. 07-0225

 

Dear Mr. Gluntz:

 

This responds to your November 28, 2007 email and subsequent telephone conversations requesting clarification of the general design requirements for DOT portable tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether installing a "bleed off valve" assembly as a component of the pressure relief system for a DOT 51 portable tank is prohibited and requires a special permit to install.

 

Your enclosed sketch indicates the bleed off valve assembly would be installed between the pressure gauge/tell-tale indicator and the pressure relief device to allow for the safe removal of vapors trapped in the void space should a leak occur in the frangible disc.

 

It does not appear that the installation of the bleed off valve assembly involves a modification of the DOT 51 portable tank that would invalidate the ASME U stamp.  Therefore, the bleed off valve assembly installed as a component of the pressure relief system as shown in your sketch is not prohibited and does not require a special permit to install.  However, we highly recommend the use of good engineering practices (e.g., a leakage test) when installing the assembly.  A report of the installment and any testing must be made a part of the records for the portable tank.

 

I hope this information is helpful.  Please contact us if you require additional assistance.

 

Sincerely,

 

 

Hattie L. Mitchell

Chief, Regulatory Review and Reinvention.

Office of Hazardous Materials Standards

 

178.275(g)(3)

Regulation Sections